What evidence do auditors commonly ask for on SC-28 Protection of Information at Rest?

Identification of at-rest locations including provider systems; Protection applied and evidence of it; Key management arrangements where the provider holds keys.

What is the most common gap auditors find on SC-28?

provider holds both data and keys with no analysis of that concentration

NIST SP 800-161 Rev 1 (supply chain) · C-SCRM Family: System and Communications Protection

`SC-28` Protection of Information at Rest

Protects organizational information at rest wherever it sits, including on supplier and provider systems.

Source: NIST SP 800-161 Rev 1 (supply chain), SC-28. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open NIST SP 800-161 Rev 1 (supply chain) in the compliance library.

artefacts

held by a system

at each review

hard

to go live

Document repository

where the evidence lives

teal = a system already holds it · olive = produced at each review. To go live: easy when half or more of the artefacts are already held by a system, moderate from a quarter to a half, hard below a quarter.

These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.

system holds itEvidence a system already holds

none for this control

periodic reviewEvidence produced at each review

Protection applied and evidence of it · Document repository

governing documentDocuments that govern the control

Identification of at-rest locations including provider systems · Document repository
Key management arrangements where the provider holds keys · Policy repository / GRC workspace

First move

No system holds this evidence for you: it is people and documents. Reminders and routing to the owner still save time. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date.

Common gaps auditors find

provider holds both data and keys with no analysis of that concentration
backups at providers unprotected

Do this for your whole sheet

Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.

Build my evidence sheet

SC-27 Platform-Independent Applications · SC-29 Heterogeneity